Just two weeks after calling FedBizOpps.gov the WORST WEBSITE in GOVERNMENT, there is a light at the end of the tunnel.

The General Services Administration quietly let those who were paying attention know that the new FBO.gov will migrate to beta.SAM.gov late in calendar year 2019.

In the first quarter 2019 Integrated Acquisition Environment (IAE) digest released last week, GSA’s Vicky Niblett, the deputy assistant commissioner for IAE in the Federal Acquisition Service, wrote, “We’ll be unveiling our newest roadmap and schedule in the second quarter, but we already know that [Wage Determinations Online] WDOL.gov will be the next IAE system to transition into beta.SAM.gov. After that will be FBO.gov, probably sometime in late 2019.”

Wait, that means we have to put up with the 15-year-old site that’s stuck in the 1990s for only a few more months?

Let’s not put the champagne on ice quite yet, but you know I’m ready to celebrate.

Now after expressing my continued frustration with FBO.gov, a former FAS systems guy tweeted at me reminding that maybe I should use the beta.SAM.gov site.

That’s a fine idea, so over the next few weeks, I will commit to testing out the new site – just like I used FBO.gov – and will report back with an analysis.

In the meantime, Niblett said GSA also will make other changes to beta.SAM.gov, including adding login.gov to the registration process and implementing ‘federal hierarchy,’ which is an internal process through which appropriate roles can be assigned to federal government workers.

In related news, GSA announced that IBM would continue to provide maintenance and migration support for the SAM.gov effort.

The agency awarded IBM a sole source contact worth $24 million over the next four years.

GSA awarded IBM the initial contract in 2010 and experienced some initial challenges with the program. But GSA says in its sole source justification that IBM has delivered good performance.

“During IBM’s eight years of performance on the SAM-AOCS contract, they have gained substantial knowledge of IAE systems. They have repeatedly delivered good performance and have improved over time,” GSA states in the justification. “IBM has gained the most technical knowledge of IAE systems among any source in the marketplace. Additionally, the SAM legacy systems are at the end of their product life and are scheduled to be retired and their functions transferred to the GSA cloud business platform over the next one-to-three years. The timing will depend on funding, completion of new system modules and applications, and the number of hurdles encountered during transition to the new information technology platform. It is considered impractical and risky to have a new contractor step in at this phase of the work, which is in the final steps of a 10-year project. For reasons of continuity during completion of the work, it would not be advantageous to the Government to solicit a new full and open RFP.”

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Innovation is one of those overused words in the federal sector. Every agency wants innovation. Every vendor says what they do is innovative.

So what makes a program or initiative innovative? Like the Supreme Court famously said about something else, “you know it when you see it.”

That’s the case with the FBI’s new Innovation Council.

Jeremy Wiltz, the FBI’s assistant director IT enterprise services division, said the council, which is just getting started, will bring together a diverse set of people, both those who have been at the bureau for a long time and newer employees, to generate ideas and focus areas.

“I have IT specialists that support tier one, that support desktops and visit customers. In our headquarters building with 11 floors and people going all over the place, we came up with an idea of a solutions center. We kind of tried to make it like an Apple store where people come to us in a central location in the building and get service,” Wiltz said at a recent AFCEA Bethesda event. “I had a couple of folks who were instrumental in making this very successful. One of them came to me and asked ‘how do we do more of this?’ And he said, ‘there are more of us like me.’ So I said, let’s come up with this idea of an innovation council.”

He said the goal of the council is to encourage employees to come up with ideas to improve processes and procedures and have a place to go where someone will assuredly listen to them.

“I want to hear from them and be able to say, ‘is that a tasking you can take?’ I don’t want to derail or circumvent their management so they will have to take this on as additional duty,” he said. “But it’s very rare to find those kinds of people who came to me. If I ignore this, I’m ignoring a whole set of people who are motivated to do things and not just sit around and wait for things to happen.”

One obvious idea the council may work on is franchising the solutions center concept to other FBI offices at Quantico or regionally.

“Franchising in the government, who’s talking about that? That, in and of itself, is an innovative idea. That wouldn’t have come about if these people weren’t motivated themselves and willing to approach me,” he said. “So having that kind of courage, I thought I have to take hold of that. I can’t wait to see where it goes.”

Wiltz offered an update to the council last week. He said the innovation council continues to come together.

“The individuals leading the effort are currently working behind the scenes to ensure alignment on mission, vision and goals prior to establishing a formal charter,” he said in an email to Federal News Network. “The innovation council will be composed of a diverse cadre of employees, working in the field and at headquarters across a variety of roles (IT and non-IT). Participants will share an interest in leveraging innovation solutions to make the FBI more efficient. Topics and priorities are still to be determined but one of the primary focus areas will be improving customer service.”

Giving employees a real voice in change

What makes the FBI innovation council so “innovative” is the simple fact that they are listening to the employees on the ground. Too often agencies want innovation to come from outside the agency, like the Defense Department’s Innovation Board. The DIB is made up of well-known technology industry experts like Eric Schmidt, founder of Google, and professors from Duke University, the California Institute of Technology and Carnegie Mellon University, who are helping the Pentagon take on enterprisewide issues.

Other efforts such as the Obama administration’s SAVE awards petered out after several years, and it’s unclear if any of the ideas that emerged from the frontline employees were ever fully implemented.

Michael Giuffrida, the CEO of Acendre, said engaging employees and giving them a real voice to drive change is much easier said than done.

“There are a lot of organizations out there where they give employees the opportunity to be heard through things like pulse surveys or in other ways. But how do you take that feedback and act on it?” Giuffrida said. “It’s important for employees to see the change that comes from their ideas. If they don’t see that change that’s where these efforts fail. It’s all about how you turn ideas into action and close the feedback process. That is where you see positive outcomes of engagement.”

Giuffrida said employee engagement “fits hand-in-glove” with increasing productivity and mission success.

“[From] the metrics we look at – on average – people are losing $9,000 per employee a year due to a lack of engagement in terms of productivity. If you have 100,000 employees, that’s a lot of money,” he said. “So if you can move the needle 10 percent-to-20 percent, that’s a lot. It’s important and getting mission critical especially when we are all fighting all the dynamics in the federal space.”

Giuffrida added that the dynamics include budget uncertainty, shutdowns and the arduous hiring process, all of which make it more difficult to bring innovative approaches into government.

Not if, but when apps move to the cloud

And this brings us back to the FBI’s innovation council.

Wiltz said new ideas and approaches become more important as the FBI moves more apps to the cloud.

“I see going into the cloud as a force multiplier. You have Amazon, Microsoft, Google’s security operations center on top of your SoC and their layers of security on top of your layers of security,” Wiltz said. “My boss has put out a vision, a toolbox of the future. We are beginning to plant it in the minds of people who don’t think the way we think or don’t think about moving toward mobility. We are starting to plant those seeds.”

And what better way for those seeds to grow and prosper than by seeking the input and backing of the people who are going to reap the harvest.

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When you dive into the fiscal 2019 budget sometimes you need a miner’s hat, and sometimes you need to be an oil driller.

Where a miner must go underground and chip away at rock to find the IT “gold,” a driller just has to know where to start.

That is the case with cybersecurity in the 2019 budget — hitting just the right spot brings a gusher of black cyber gold.

The best place for drilling is in the Department of Homeland Security’s section where the Cyber and Infrastructure Security Agency (CISA) now lives.

In this region of DHS, lawmakers allocated CISA $322.8 million for “procurement, construction, and improvements.”

To get the oil out of that field, you have to start boring some holes, first in the continuous diagnostics and mitigation (CDM) program. CDM received two funding allocations: The first is for deployment of capabilities where DHS received a total of $115.8 million, which is $3.7 million more than the Trump administration requested and $13 million more than CDM received in 2018.

But that’s a minor gusher compared to the money DHS received for the procurement of tools. Congress allocated $160 million for DHS to buy agencies new tools under CDM, which is $34.4 million more than the White House requested, but almost $87 million less than what the program received in 2018.

Now with Congress acting as the investors in this CDM Spindletop-of-sorts, they want updates on how DHS is pumping out their profits.

“CISA is directed to provide a briefing, not later than 90 days of the date of enactment of this act and semiannually thereafter, on the updated timelines and acquisition strategies for the National Cybersecurity Protection System (NCPS) program and the Continuous Diagnostics and Mitigation (CDM) program, including the accelerated deployment of CDM Phase 4 data protection management (digital rights management, data masking, micro-segmentation, enhanced encryption, mobile device management, etc.) across all ‘.gov’ civilian agencies,” the omnibus spending bill states.

While the CDM field continues to flow millions of gallons of oil, the NCPS program, which includes the Einstein intrusion and prevention tools, is starting to dry up for tool procurement.

Lawmakers allocated $96 million in total funding for this year, down from $115 million last year and $5 million less than what the administration requested.

“A reduction of $15 million to the NCPS acquisition program is included due to contract delays,” lawmakers write.

But at the same time, lawmakers increased NCPS funding to $297 million for deployment of NCPS tools, up $10 million over 2018 and about $600,000 more than the administration requested.

The third piece of the federal cybersecurity funding came to the Federal Network Resilience group at DHS. It received $50.1 million for 2019, which is $7.3 million more than in 2018 and slightly over the administration’s request.

Lawmakers also told DHS to redirect some of their extra funds for “facility construction, expansion and renovations necessary to support CISA’s growing cybersecurity workforce; expanding operations, laboratory, and logistics support activities; and Continuity of Operations functions at the agency’s existing support facility. In fiscal year 2018, $500,000 was appropriated for facility design purposes.”

The DHS oil fields are well known for their gushers, but the 2019 spending bill also had some lesser known fields for some deeper drilling.

Supply chain risks continue for CJS bill

In the Commerce, Justice and State bill, lawmakers reemphasized supply chain risk management.

Legislators told those agencies, including NASA and the National Science Foundation, they can’t buy any technology for high or moderate impact systems unless:

• They have reviewed the supply chain risk for the information systems against criteria developed by the National Institute of Standards and Technology and the Federal Bureau of Investigation (FBI) to inform acquisition decisions;
• They have reviewed the supply chain risk from the presumptive awardee against available and relevant threat information provided by the FBI and other appropriate agencies; and
• They have consulted the FBI or other appropriate federal entity, conducted an assessment of any risk of cyber-espionage or sabotage associated with the acquisition of such system, including any risk associated with such system being produced, manufactured, or assembled by one or more entities identified by the United States government as posting a cyber threat, including but not limited to, those that may be owned, directed or subsidized by the People’s Republic of China, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, or the Russian Federation.

Additionally, lawmakers say these agencies must not buy technology for high or moderate risk systems unless the agency has “developed, in consultation with NIST, the FBI, and supply chain risk management experts, a mitigation strategy for any identified risks; determined, in consultation with NIST and the FBI, that the acquisition of such system is in the national interest of the United States; and reported that determination to the Committees on Appropriations of the House of Representatives and the Senate and the agency Inspector General.”

These provisions follow a long history of concerns at these agencies over supply chain risks. In 2014, former Rep. Frank Wolf (R-Va.), added a similar provision in that year’s spending bill.

Treasury, Transportation get cyber funds

Two other regions ripe for bringing in rigs for drilling is in the Treasury and Transportation sections of the bill.

First, the Treasury Department received $25.2 million for enhanced cybersecurity services and personnel. Lawmakers instructed Treasury’s bureaus to send the agency’s chief information officer a spending plan for approval.

In the Transportation Department sector, you had to drill a little deeper to find $15 million in cyber oil.

Lawmakers told Transportation to use the money for “necessary expenses for cybersecurity initiatives, including necessary upgrades to wide area network and information technology infrastructure, improvement of network perimeter controls and identity management, testing and assessment of information technology against business, security and other requirements, implementation of federal cybersecurity initiatives and information infrastructure enhancements, and implementation of enhanced security controls on network devices.”

This is, by far, not a comprehensive review of all things cyber in the spending bill. Congress also allotted quite a bit of cyber money for election security, critical infrastructure protections and research and development. But the cyber spending highlighted above are what will impact agency security postures in real and immediate ways.

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The movement in the federal chief information officer’s community has been quiet over the last few months. But two agencies finally filled CIO positions that have been open for almost a year.

The U.S. Patent and Trademark Office named Henry “Jamie” Holcombe to replace John Owens, who left in November 2017. David Chiles, PTO’s chief technology officer, has been acting CIO since Owens left to work for CGI Federal as its vice president of its Solution Development for Emerging Technologies Practice.

Holcombe starts at PTO on Feb. 25, coming to the agency after a career in the public sector.

He is leaving his position as vice president and general manager at Harris Corp., where he was responsible for the delivery of communications and IT services to federal intelligence, defense and civilian markets as well as commercial telecom, energy and e-commerce customers.

In addition to Harris, Holcombe worked at the Universal Service Administrative Company, Globix Corporation in New York, and served as chief operating officer of TJ Westlake and chief executive officer of Visium Technologies, focusing on cybersecurity at both companies.

“Our legacy IT systems are old and it is well beyond time to undertake a fundamental stabilization and modernization effort. As our new CIO, Jamie will have a unique opportunity to help the USPTO improve these systems and transition our agency to state-of-the-art technology,” said Under Secretary of Commerce for Intellectual Property and Director of the USPTO Andrei Iancu in a statement.

Holcombe’s priorities at USPTO are well known. He will continue to decrease the patent backlog and modernize both the patent and trademark systems. Owens modernized the bureau’s processes by implementing dev/sec/ops.

Holcombe holds a Master of Science in computer science from George Washington University, and a Master of Business Administration from Chaminade University. He also has a Bachelor of Science degree from the United States Military Academy at West Point, where he finished first in his class in computer science.

CIOs shifting among small agencies

In addition to the USPTO, the U.S. International Trade Commission replaced its CIO with an internal candidate.

Keith Vaughn, who joined the agency in 2011 as its chief data architect, replaces Kirit Amin, who left in January 2018. Vaughn also was acting CIO from January to September 2018.

Before coming to USITC, Vaughn worked at several contractors in senior level positions, including The Ambit Group, SI International and Zen Technology.

As the CIO, he will develop and manage the agency’s information technology budget, work with offices throughout the agency to ensure that their information technology requirements were met, strengthen the agency’s network security and direct a number of crucial information technology modernization and enhancement efforts.

Two other small agencies have put out the “help wanted” sign for CIOs.

The Millennium Challenge Corporation posted a job notice on USAJobs.gov that closes on Feb. 22.

MCC’s previous CIO, Vincent Groh, passed away unexpectedly in October, according to the agency’s release.

“Vince was an important member of the management team, and a respected leader who demonstrated compassion and teamwork. He was committed to working with others to find solutions, and empowered his team to provide best in class services to the agency,” the agency states. “Through his passion for MCC’s mission, and dedication to his work, Vince embodied the finest values of MCC. Our thoughts and prayers are with his loved ones. He will be profoundly missed.”

Christopher Ice, MCC’s senior director of production operations in the office of the CIO, has been acting CIO since October.

Groh was a guest on Ask the CIO in August 2017 where he talked about how he was planning on moving MCC to the cloud and stop spending on commodity technologies.

Additionally, the Institute of Library and Museum Services is hiring a new CIO. Ben Sweezy, who started as the CIO in January 2018, changed positions and is now the deputy director of the Office of Digital and Information Strategy.

It’s unclear if Sweezy, a former Office of Management and Budget IT policy analyst, or Eugene Block, the deputy CIO at ILMS, is currently acting CIO.

The USAJobs.gov notice closes on Feb. 22 and states that the CIO role oversees both their office and the Office of Digital and Information Strategy.

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Now that another shutdown has been avoided, and agencies and contractors can get back to the real work of government, it’s time to dig deep into the fiscal 2019 omnibus spending bill for technology nuggets.

Like any worthwhile mining operation, it may be some time until we really know what we have, but at first glance, there’s a lot of gold in them thar’ hills.

The first nugget you’ve probably seen is the Technology Modernization Fund (TMF) receiving $25 million for 2019. That was a big drop from 2018 when the TMF Board had $100 million to loan out to agencies. By the way, the board still has about $10 million in 2018 funding that must go out the door – so we can say for this year the total amount is $35 million.

It’s a big drop from the Trump administration’s request of $210 million, and even from the House Appropriations Committee’s initial allocation of $150 million. The silver lining here is the Senate had zeroed out the fund so getting $25 million is progress.

Once you get past this initial TMF vein, the mining operation uncovers an interesting provision in the state/foreign operations section of the mountainous bill.

Lawmakers limited the State Department and the U.S. Agency for International Development’s use of the no-interest loan mechanism.

“None of the funds made available by this Act and prior Acts making appropriations for the Department of State, foreign operations and related programs may be used by an agency to submit a project proposal to the Technology Modernization Board for funding from the Technology Modernization Fund unless, not later than 15 days in advance of submitting the project proposal to the Board, the head of the agency (i) notifies the Committees on Appropriations of the proposed submission of the project proposal; and (ii) submits to the Committees on Appropriations a copy of the project proposal,” the bill states.

Additionally, legislators added that even if the board approves State or USAID’s project, the agency head must submit “to the committees on appropriations a copy of the approved project proposal, including the terms of reimbursement of funding received for the project; and (ii) agrees to submit to the committees on appropriations a copy of each report relating to the project that the head of the agency submits to the board.”

No other section of the omnibus spending bill has a similar provision, and there is no more discussion in the current omnibus bill nor the previous House or Senate reports issued in summer 2018 about why lawmakers have concerns about State or USAID using the TMF.

At the same time, miners uncovered another vein of gold that takes us in a totally different direction. This one seems to reiterate and reinforce the State Department’s chief information officer’s authorities.

Lawmakers wrote: “None of the funds appropriated in title I of this act under the heading “Administration of Foreign Affairs” may be made available for a new major information technology investment without the concurrence of the CIO, Department of State. (B) In complying with the requirements of this paragraph, the CIO, Department of State, shall consider whether a new major information technology investment- (i) is consistent with the department Information Technology Strategic Plan; (ii) maintains consolidated control over enterprise IT functions or improves operational maintenance; (iii) improves Department of State resiliency to a cyber-attack; (iv) reduces department of State IT costs over the long-term; and (v) is in accordance with the Federal 6 Acquisition Regulation (FAR), including FAR Part 6 regarding competition requirements.”

It’s well known in the federal IT community that the State CIO has struggled for decades to oversee IT investments by the foreign service.

Former State CIO Frontis Wiggins sought to create IT franchises where the headquarters’ CIO office acts like the parent company and provides the basic services to the franchisees. That idea never made much progress as Wiggins left before he implemented it. Now State is going down the more traditional path of trying to convince it’s powerful brethren that back-office shared services is a better approach to give the CIO more visibility and oversight.

Congress possibly just got tired of these approaches that made little or no difference, and brought down the hammer in a different way to empower the agency CIO.

CIO powers continued

It’s not just at State that lawmakers used the omnibus to reiterate and reemphasize the role and authorities of agency CIOs.

In the Agriculture Department’s section, lawmakers added a provision to ensure that the CIO, Gary Washington in this case, and the executive investment review board approves any new or significant upgrade of IT.

But then legislators took an interesting turn in the provision.

“None of the funds appropriated or otherwise made available by this act may be transferred to the Office of the CIO without written notification to and the prior approval of the committees on appropriations of both houses of Congress: Provided further, That, notwithstanding section 11319 of title 40, United States Code, none of the funds available to the Department of Agriculture for information technology shall be obligated for projects, contracts, or other agreements over $25,000 prior to receipt of written approval by the CIO: Provided further, that the CIO may authorize an agency to obligate funds without written approval from the CIO projects, contracts, or other agreements up to $250,000 based upon the performance of an agency measured against the performance plan requirements described in the explanatory statement accompanying Public Law 113- 5 235.”

So let’s break that down, the Appropriations Committees must approve any transfer of funds to the CIO, but the CIO may approve any IT purchases over $25,000 and in some cases up to $250,000.

Again, this is why miners don’t always know what they have until there is further inspection to know if it’s gold or pyrite.

Lawmakers also reiterated — in Section 623 — the authorities CIOs received in the Federal IT Acquisition Reform Act (FITARA), the Clinger-Cohen Act and several White House policies and executive orders.

It’s unclear why there is this need to reiterate a law in another law, but as miners, we have to keep on digging to find out what’s underneath this layer of rock.

IT modernization funding in different accounts

Sometimes you have to blast through other rock formations to reach new sources of minerals. This is the case for IT modernization. While the TMF is specifically designed to provide agencies with a loan to further existing initiatives, the Office of Management and Budget and the General Services Administration also have other accounts that can further the goals of getting off legacy systems.

OMB received a $9.5 million increase over 2018 in the IT Oversight and Reform (ITOR) fund to $28.5 million.

“OMB is expected to utilize the funding provided to continue oversight of federal IT activities and investments, including the management of the IT Dashboard, the OMB policy library, and IT policy compliance tracking,” the appropriators wrote.

While this funding can’t be used as a loan, OMB can provide agencies help in other ways to make IT modernization easier by updating acquisition policies for buying technology or the creation of training courses.

Additionally, GSA received a boost to the $55 million Federal Citizen Services Fund, which is $5 million more than it received last year.

GSA said in its 2019 budget justification that it will use the fund to pay for the Federal Risk Authorization Management Program (FedRAMP) and to further the Login.gov initiative.

Both could be key pieces to help agencies modernize services as we’ve seen with 128 cloud services approved through FedRAMP and another 73 in the process. Login.gov has been picked up on the SAM.gov, USAJobs.gov and Trusted Traveler websites.

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The perception that bid protests are mucking up the federal procurement process is one of those urban myths that will not die, like how Paul McCartney died in a car crash in 1966 or that the Air Force hides away UFOs in the desert.

Despite the fact that these “theories” are continually disproven, the myths just will not go away. Plenty of people swear they hear “Paul is dead” when you play “Revolution No. 9” backward.

For instance the most recent attempt to limit bid protests to improve acquisition is from the Section 809 panel. It recommended making substantial changes to the federal bid protest process by limiting vendors to filing before the Government Accountability Office or the Court of Federal Claims, but not both, as well as prohibiting protests of contracts for “readily available” products or services of less than $15 million.

The Senate Armed Services Committee a few years ago tried to “restrain” bid protests by making it harder on contractors to bring complaints before the GAO.

Despite the well-known fact that protests impact less than 1 percent of all procurement actions a year, there is this ever-present concern that bid protests are fouling up the system and a major part of the reason why federal contracting takes so long.

But what if the answer wasn’t changing the processes, but it was to make contracting officers, source selection committees and lawyers better communicators?

That is the goal of the latest initiative by the General Services Administration called INFORM, which stands for In-Depth Feedback through Open Reporting Methods.

“Our hypothesis is that giving offerors or industry more insight into why they did or did not receive a specific award will help them improve the quality of their future submissions. Our hope is that INFORM will deliver some of the same benefits through broader communication as evidenced with early engagement,” Jeff Koses, GSA’s senior procurement executive, wrote in a Feb. 7 blog post. “GSA’s current post-award communications are already more robust than those outlined in the Federal Acquisition Regulation (FAR). INFORM complements this by providing each offeror with an unsolicited customized evaluation statement, an opportunity for an in-person oral feedback meeting with the GSA evaluation team, and the option to submit written follow-up questions.”

What Koses really is talking about is enhanced debriefings, a process the Defense Department, the Department of Homeland Security and others have begun to implement.

Congress instructed DoD in the 2018 National Defense Authorization Act to give unsuccessful bidders more details in the form of written questions and answers. DoD issued a FAR deviation in March 2018 detailing the process and timelines.

DHS, through its Procurement Innovation Lab (PIL), has initiated more discussions with industry and sooner in the process.

GSA’s nine-month, 50-acquisition pilot is further recognition that talking to vendors about why they lost and what they can do better in the future has all sorts of benefits. Koses also issued a memo detailing how the INFORM pilot would work back in October, which included metrics for success.

“We anticipate that adding more information and transparency to the post-award communication process will improve offerors’ perception of the fairness and impartiality of GSA’s award decisions,” Koses said in the blog.

Current debriefings lack substance

This is because the current approach isn’t working.

“Most debriefings handled through written, short explanations about why you lost, and they are totally ineffective,” said Rob Burton, an attorney with Crowell & Moring and former deputy administrator in the Office of Federal Procurement Policy. “They raise all sorts of questions for contractors which are never answered but many times only through the bid protest process.”

Burton has long been a supporter of enhanced debriefings, offering up one experience where he had to convince an agency to show him contracting documents or face a bid protest. When he finally saw the documents, Burton recommended to his client that they not protest because they couldn’t win.

“Bid protests have an enormous impact on agency personnel, lawyers and others,” he said. “But doing an enhanced debriefings for an hour or so will be much less time than supporting a bid protest process that could go on for an extended period of time.”

Experts praised GSA’s decision to take on enhanced debriefings. GSA Administrator Emily Murphy outlined improving debriefings as one of her initial priorities.

Charles Tiefer, a professor the University of Baltimore law school, said it’s clear industry is driving the need for enhanced debriefings. He said the standard, cookie-cutter written explanations just aren’t good enough these days, especially as the procurements become more complex.

“First and foremost, enhanced debriefings improve competition. The bidders who tried and lost will learn what they did wrong so they can bid better the next time. That’s vital because you don’t want the same contractors to win over and over,” he said. “The ones which are making some kind of mistake need to know what they are so they don’t make the same mistakes over and over and never become serious competitors.”

Tiefer said he is concerned that contracting officers will be unhappy with enhanced debriefings because they already are overworked.

He said GSA and other agencies should come up with metrics that show the success of enhanced debriefings, such as decrease in the number of protests or the time it takes to prepare a detailed conversation compared to the time it takes to address a protest.

Industry wants more information

Michelle Currier, a professor of contract management at the Defense Acquisition University, said enhanced debriefings may not have a big impact on bid protests, but improved industry bids is the biggest benefit.

“We have to recognize that government is no longer the best and only game in town. We need to look for ways to make federal procurement more attractive for innovative and new companies to invest and help us solve our problems,” she said. “Industry has said they don’t learn anything of value in a standard debriefing to make us come and do it better. So the more conversations we have with industry, it will keep them encouraged to do business with us.”

Tim Cooke, president and CEO of ASI Government, said there are four specific things agencies should keep in mind as they do debriefings. ASI Government helps agencies prepare acquisitions and documents for post-award debriefings, but do not participate in the actual sessions.

• Consistency: Cooke said agencies need to follow the same pattern when exchanging information with industry. “A debriefing should just be a new chapter in same story,” he said.
• Participation of the entire team at the debriefing: Cooke said the meeting shouldn’t just be the contracting officer or program manage, but also many, if not all, of source selection technical team. “A contracting officer is not going to be able to do a substantive debrief without a technical evaluation team,” he said. “Too often contracting officers are put in that situation and that’s why vendors come away feeling unsatisfied.”
• Don’t be afraid to talk: Vendors aren’t there to receive written comments but to ask questions and understand where they went wrong. Cooke said agency contracting executives need to be confident in their decisions and answer questions in a way that exudes that confidence, but also provides answers to vendors’ questions.
• Transparency: Share everything that is relevant with the unsuccessful bidders. Cooke said if the vendor files a protest, all the documents will come out anyways so it’s better to make them available sooner than later.

“And keep the lawyers on the sidelines for both sides. Once they are in the game, they have to prove their value and it’s a drag,” Cooke said. “Fear of protest is the number one reason why more information isn’t shared. But if you have done a good job, then there is reason to hold back.”

And it’s that confidence that DoD, DHS and now GSA must exude during these enhanced debriefings.

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Congress needs to rethink its requirement for the General Services Administration to pilot and eventually set-up a new e-commerce platform.

Lawmakers should tell GSA to pause its efforts before any more money is spent by the government or by industry.

If the goal of the e-commerce marketplace is to give agencies easier access to commercial products, to obtain better data on what products agencies are buying and to save money, the smarter, more economical and more pragmatic approach would be to fix GSA Advantage and not develop something new.

The fact is GSA Advantage already accomplishes two of the three goals of the e-commerce marketplace, and addressing the data issue isn’t that much of a stretch.

The reason why Congress, and even GSA and the administration, should rethink the e-commerce platform is time and again independent, third party researches have proven GSA Advantage to meet a majority of the goals under Section 846 of the 2017 Defense authorization bill.

The latest example comes from the Coalition for Government Procurement, which analyzed 744 AbilityOne products on GSA Advantage and on a platform run by Amazon under a pilot program.

CGP found 741 out of 744 items on GSA Advantage had better prices as compared to the AbilityOne and Amazon site. Even when CGP accounted for minimum order quantities required under the government’s buying platform, GSA Advantage still provides agencies with a better deal 72 percent of the time and prices were lower 56 percent lower on Advantage as compared to the Amazon pilot.

Roger Waldron, the president of CGP, said his association’s analysis as well as one from the Naval Postgraduate school debunks the urban myth that GSA schedules aren’t competitive.

“For years, there’s been this complaint about GSA and its pricing and I think this study and the Naval Postgraduate school study shows this is a competitive marketplace,” said Waldron, who also hosts Off the Shelf on Federal News Network. “The thing about the schedules marketplace is there are additional layers of competition that can be had when you leverage requirements and get quotes that further lends itself to providing value to the government. So rather than doing micro purchase after micro purchase, you can leverage those buys through the schedules program.”

GSA Advantage is 80 percent lower

The December 2017 study by Air Force Capts. Holland Canter and Tabitha Gomez at the Naval Postgraduate School provided similar findings as the CGP report.

Canter and Gomez looked at an Air Force pilot with Amazon and GSA Advantage for credit card purchases.

Canter and Gomez found “of 300 vendors that offered the 60 compared items, GSA Advantage offered the lowest price 80 percent of the time (241 times out of 300). Although GSA Advantage offered the lowest price more frequently, every item had a minimum order requirement. Amazon Business did not have any stated minimum order requirements for any items that we examined.”

Both studies found some definite benefits with Amazon’s portal.

Waldron said the CGP study found that the Amazon portal with AbilityOne was more user friendly and easier to find products thanks to a landing page and search logic.

“There are some pop-ups that come up when you are looking and searching on the commercial tool that AbilityOne would want to look at in regard to the ‘essentially the same’ concept to see how that could work in the future,” he said.

The study also states, “[Amazon-AbilityOne] usually has effective and consistent product names; technical information, such as the size and weight of a product; and accurate photos of the product.”

The Naval Postgraduate School study found, based on interviews with users, that GSA Advantage’s requirement of minimum order quantities was unpopular, and gave Amazon a boost because it doesn’t have the same requirement.

“From our results, we infer that users preferred Amazon’s platforms for several reasons. First, the platform is used widely in the commercial sector and many people use Amazon in their personal lives. The platform provides a vast selection of supplies, product ratings and vendor ratings while also offering two-day delivery for most items,” the authors wrote. “We also found that older respondents were less likely to prefer Amazon.com or Amazon Business, compared to younger respondents. This is likely because older than 65 respondents are more familiar with GSA Advantage. They have used the platform for many years.”

The authors also found purchase card users said that while GSA Advantage worked well for purchases above the micro-purchase threshold and strategic sourcing initiatives, they didn’t like the minimum purchase requirements, shipping policies, return policies or search engine results page.

Both GSA and Amazon offered little insights into their individual thoughts about the CGP analysis.

“The Federal Acquisition Service (FAS) is committed to providing best value offerings to our customers. Purchasing through our multiple award schedules and global supply programs promotes compliance in meeting the mandatory AbilityOne purchasing requirements,” said Alan Thomas, the commissioner of FAS, in a statement to Federal News Network. “Through our Federal Marketplace Strategy, GSA wants to make it easier for our customers to buy solutions and for industry partners to offer them, including AbilityOne items. GSA is continuously improving existing platforms and developing new ones as we enhance the buying and selling experience.”

And Anne Rung, the former administrator in the Office of Federal Procurement Policy and now the director of Amazon Business government sector, said in a statement to Federal News Network that “Amazon Business provides government customers with another option for their purchasing needs, offering a combination of selection, convenience and value with features and benefits tailored to the needs of public sector organizations. These features and benefits simplify the procurement process and increase efficiency for procurement officials, who can spend more of their time focusing on mission-critical projects.”

Amazon has been a big supporter of the e-marketplace concept because, as Rung said in June, it can give the government more transparency and more efficiencies.

Recommendations for improvement

OFPP said in December it wanted to limit purchases during the e-commerce pilot to $10,000, below the micro purchase threshold. Many of these purchases now are done through government purchase cards. GSA announced earlier this month that agencies spent a record $30.6 billion in fiscal 2018, $2 billion more than the previous year, through the SmartPay program.

This leads back to both the CGP and Naval Post Graduate School studies. The researchers reviewed products that were under $100, meaning many of those items would normally be purchased with credit cards so creating a new e-marketplace to track this spending instead of just working with the credit card vendors is yet another reason for Congress to revisit this decision.

CGP included in its study some areas for GSA and OFPP to consider more closely as it conducts the e-marketplace pilot.

“We like to look at it from our members’ perspective to increase opportunities through e-commerce. So what does that mean? Making improvements to GSA Advantage by developing logical search capabilities that make it easier to use to take advantage of that competitive pricing that GSA has been able to establish,” Waldron said. “What role should e-commerce platforms play in the commercial market? Should they be part of the conversation and part of the solution? Absolutely, but what does that look like? We need to create opportunities for commercial firms across the board. It can’t be a zero sum game where you are taking one set of requirements and moving it to another place. I don’t think the government gets a better deal.”

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In Star Trek, Captain of the Enterprise James T. Kirk often spoke those famous words, “Mr. Sulu, take us to warp speed.”

Harry Potter donned the invisibility cloak seven times over the course of those eight best-selling books. And Peter Hamilton’s 2004 book “Pandora’s Star” described how humans harnessed wormhole technology to colonize hundreds of planets in the far-off future.

Warp speed, invisibility cloaks and harnessing the power of wormholes are three of 18 areas of research the Defense Intelligence Agency spent more than $20 million on in the mid-2000s. But before you mock DIA or chalk it up to another example of government squandering money, keep in mind that these movies and books, and hundreds more like them, spark our imagination and make us wonder what the future might actually look like.

That is why the DIA’s projects are so fascinating. The Federation of American Scientists obtained the list of reports from DIA under a Freedom of Information Act (FOIA) request.

DIA paid $22 million between 2007 and 2012 for research under the Advanced Aerospace Threat and Identification Program (AATIP), which many have called former Sen. Harry Reid’s (D-Nev.) UFO pet project.

“At first glance it looks like a pretty wild list of topics. I think that will be most people’s reaction to seeing these things because they do seem sort of far out there. But if you look at it with a little more context about what DIA’s role is and the nature of intelligence more generally, it’s not quite as wild of a list at first glance,” said John Amble, editorial director at the Modern War Institute at West Point. “One of the requirements of intelligence is to do strategic forecasting. If you start looking at strategic intelligence, you are looking generations into the future in some cases and certainly generations in terms of equipment, weapons and platforms.”

Amble said too often DoD is particularly focused on tactical level intelligence, so for DIA to look at weapons and technology that is “far out there” is important.

DIA encourages researchers to dream a little

August Cole, a non-resident senior fellow at the Atlantic Council and co-author of “Ghost Fleet,” went even further, saying it’s critical for DoD, military researchers and contractors to “dream a little bit” to overcome traditional blind-spots in planning.

“I think this list accurately reflects what the future of war forecast might look like,” Cole said. “It’s easy to dismiss the research that they were undertaking and exploring, but the reality is the speed at which war is moving is going to require the kind of technical solutions from the lasers we see today becoming more operational to invisibility cloaks that an individual solider could wear or could be applied to an aircraft like the F-22.”

Cole and Amble say DIA — or any agency for that matter — funding this type of research is critical to opening up some potential innovations.

Cole said science fiction books from 100 years ago were filled with all kinds of concepts and ideas that became reality today like the machine gun, the rocket and, probably the most famous one, lasers.

“The reality is this shows the seriousness of which technology innovation needs to be treated,” he said. “It puts you in a paradox where you want to be creative and thinking through the potential rule breaking innovations that are out there that could upend the sorts of assumptions about what it means to fight a war in the same way just like a breakthrough like a machine gun, the airplane and the long-range rocket did. So we are in this position where you both need to have a loose free-wheeling style imagination mining everything from science fiction literature to kinds of traditional foresight activities, and then figuring out how to make it real.”

It’s not surprising that DIA and Reid’s decision to spend taxpayer money on these topics doesn’t sit well with everyone.

Whimsical at best, frivolous at worst

Steve Aftergood, the director of the Project on Government Secrecy at the FAS, said his first reaction to seeing DIA’s list was a little bit of anger based on the nature of the research.

“There are things imagined that never came to fruition and never will come, like warp drive, which is traveling faster than the speed of light. To invest any money in that is whimsical at best and frivolous at worst,” Aftergood said. “This work, judging from titles, is far removed from any kind of near term or long term threat to national security. It just looks like a misuse of government funds.”

Aftergood, however, said he sees the value in supporting unconventional thinking on a small scale. And $22 million on this type of research is relatively small compared to the federal research and development budget of $117 billion a year.

“They would say we are willing to be ridiculous if it means we can support someone with a vision who is really doing some far looking into future and telling us things we wouldn’t have through by ourselves,” he said. “If 99 percent of this work results in work that is junk, but if 1 percent is brilliant, then all of it is money well spent.”

And it’s that 1 percent that DoD is counting on as it must invest in the “whimsical,” must explore books and movies in the science fiction realm and must enter the worlds of Isaac Asimov and other inspiration pioneers to prepare for the next 100 years.

In fact, Cole said there are few items on DIA’s research list that may be more relevant in next 10-to-20 years, such as hyper-sonic tracking, which is a capability the Chinese, Russians and U.S. are all working on.

“These things are never simple solutions. The farther you reach, the more difficult it’s going to be whether it’s exploring the kind of meta materials that are out there today or going back to the concepts of cloaking or lasers. But at same time if you don’t attempt to explore the sorts of technology that look like they belong on a sci-fi wish list, you can be sure your adversary will be,” Cole said. “So this competitive aspect to innovation can’t be forgotten when considering a list of programs like this that looks like a potential, fantastical boondoggle but in fact may be more militarily relevant than you realize.”

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Inquiring minds wanted to know: What is the status of the General Services Administration’s new eBuy Open GSA First Pilot? So like a good journalist, I inquired.

Lo and behold, GSA posted an update to the transparency effort listing 16 requests for quotes that the agency has awarded since October and then posted on FedBizOpps.gov.

As you may remember, for the better part of a decade, I have been asking — sometimes nicely, other times less so — for GSA to make requests for proposals, requests for information and contract awards under the schedules program visible for non-schedule holders.

GSA Administrator Emily Murphy announced in May that a limited pilot would start in fiscal 2019. But since then, GSA hasn’t talked much about the eBuy pilot. So the listing of the RFQs earlier this month is a positive sign that the pilot is moving forward toward an eventual realization that making the schedules fully transparent is in the best interest for all of us.

The projects in the pilot include awards for safety helmets, multi-functional device copiers and silicon carbide disks. All of the RFQs are considered low-dollar efforts, just under $3,000 to $2.2 million.

Here’s the rub: Under further review, these RFQs are not easily found on FedBizOpps.gov — at least as far as my search skills could take me on the worst website in government.

Multiple searches under the RFQ number, the award number, even using the search term “eBuy Open” and “eBuy Open GSA First Pilot” as well as the vendor’s name came up either empty, or with so many results that it’s not worth the time or energy to track down the listing.

I finally found the RFQs by searching on Google for the RFQ number, which took me to a third party website, which had the link to the FedBizOpps.gov listing.

But using the same RFQ number provided by GSA and the third-party site, and putting it into FedBizOpps.gov, nothing comes up. Once again, demonstrating why FedBizOpps.gov is the WORST WEBSITE IN GOVERNMENT.

Remember the Bush administration’s mantra, “three clicks to service?” Well this effort mocks that simple concept.

So there is good and bad news in the first almost four months of the pilot. GSA is living up to its word in making RFQs on eBuy available after they have been awarded. But, making those solicitations easier to find would be a major step in fulfilling the goals of the pilot. Maybe that will not come until FedBizOpps.gov — the worst website in government — is finally modernized. GSA issued an RFQ under the Alliant Small Business vehicles in 2016, and eventually awarded the $11 million contract to Octo Consulting so the time should be near.

NASA doesn’t pick incumbent contractor

Shifting contracting news gears, NASA’s $2.9 billion award to Leidos to take over its end-user services and a support contract from HP Enterprise Services may seem surprising on the surface. A contractor swooping-in to steal a major multi-billion contract from the incumbent just doesn’t happen often in federal procurement. But if you’ve followed the NASA and HPES — now known as DXC Technology — ordeal, the chips were definitely stacked in favor of Leidos.

NASA awarded HPES a 10-year $2.5 billion agency consolidated end-user services (ACES) contract, and it has been plagued by service and cybersecurity problems ever since.

Starting in 2016, my reporting uncovered severe cybersecurity vulnerabilities in NASA’s network tied directly to the ACES program. Later that year, NASA CIO Renee Wynn went even further to force HPES to respond to the problems by refusing to sign a full authority to operate on ACES because of continue cyber shortcomings. Eventually, then-NASA Administrator Charles Bolden met with HPES CEO Meg Whitman to discuss the ongoing problems with ACES.

So long-story short, NASA was unhappy with the ACES contract and bringing in another vendor may have been the space agency’s only move.

Now, Leidos will run the new program, the NASA End-user Services and Technologies (NEST), which is a firm-fixed-price, indefinite-delivery/indefinite-quantity contract that has a maximum value of $2.9 billion over 10 years.

NASA says under NEST Leidos will manage most of the agency’s personal computing hardware, agency standard software, mobile IT services, peripherals and accessories, associated end-user services and supporting infrastructure.

Of course, NASA still may face a bid protest over the award. And while HPES and NASA have improved their relationship over the last year or so to fix some of the problems with ACES, Leidos still may face a significant clean-up project.

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The Section 809 panel caused quite a hubbub with its recommendation to exempt the Defense Department from the Clinger-Cohen Act—the seminal technology management law from 1996.

The panelists highlighted that the bill Congress passed and President Bill Clinton signed into law aimed to address how agencies plan, manage and oversaw long, complex IT programs, which was the norm in the 1990s.

The panel said the problem is the Pentagon now needs to move more quickly to get capabilities to the warfighter in order to keep up with China, Russia and other nation-state competitors and Clinger-Cohen is shackling DoD with 25-year-old requirements that don’t fit the modern technology approaches.

A position few would disagree with. And the recommendation to disengage DoD from Clinger-Cohen is another example of the frustration and disappointment among many in the federal community over the implementation of the 22-year-old law.

“I definitely understand why they made the recommendation and it’s not an unreasonable conclusion based on how the implementing regulation and culture has evolved. CCA isn’t perfect although I’d equate this [recommendation] to curing the disease by killing the host,” said Paul Brubaker, a former Hill staff member who helped write the Clinger-Cohen Act, a former DoD deputy CIO and now  president and CEO of the Alliance for Transportation Innovation. “The implementation of CCA within DoD has never been popular (except perhaps grudgingly when Bill Cohen was secretary of Defense). It’s seen as a congressionally and Office of Management and Budget-imposed pain in the ass and so very few civilian political IT leaders (with some notable exceptions) have understood the role enough—or had the political backing—to effectively push back both internally and externally to lead. So now, after two decades, compliance is so utterly complicated and cumbersome (e.g., the Department of Defense Architecture Framework) that it’s unmanageable — something 809 rightfully concluded. It’s not the law so much as the cumulative weight of the OMB and agency implementation guidance, self-perpetuating IT management practices and the ‘self-licking ice cream cone’ support contractors who make gobs of money ‘helping’ government comply.”

Brubaker is not alone in his candid, and maybe a little cynical, examination of why the Section 809 panel made such a hardline and somewhat shocking recommendation.

Many long-time former federal IT executives translated the panel’s recommendation to say times have changed and so too must the laws, processes and expectations of technology management.

But, they say, let’s not throw the baby out with the bathwater.

“The 809 report makes a good point that things have shifted and we no longer are buying capital assets. We are buying IT as a utility or as a service,” said Mark Forman, another former Hill staff member who helped write the law as well as a former administrator of e-government and IT in OMB and now vice president and global head of public sector for Unisys. “Clinger-Cohen focused on capital asset planning and treating IT as an investment and tying it to business results. What has changed is IT no longer requires capital asset planning and to be fair that part needs to be updated.”

But none of these long-time federal IT experts say exempting DoD from the law is the right answer to fixing the well-known and irritating after-effects of the Clinger-Cohen Act implementation.

Experts say over the last 20 years the litany of IT management laws — from the E-Government Act of 2003 to the Federal IT Acquisition Reform Act (FITARA) to the latest effort from Reps. Will Hurd (R-Texas) and Robyn Kelly (D-Ill.) called the Federal CIO Authorities — did two things: smoothed out some of the rough edges of the implementation of Clinger-Cohen, but at the same time added to the complexity of federal IT oversight.

Trapped in processes

What needs to happen, experts say, is a modernization and consolidation of federal IT laws, and therefore the processes that underlie those laws.

Bill Greenwalt, a former Senate Armed Services Committee professional staff member and former deputy undersecretary of defense for industrial policy, said DoD, and for that matter all agencies, are using antiquated approaches to capital planning and performance and results management, both of which are obstacles to faster procurements and capabilities.

“People are trapped in too many processes,” said Greenwalt, now a senior fellow at the Atlantic Council. “We are at least seven years before someone who has an idea can get it on contract. People want to do the right thing so we have to free them from some of those processes and so they can deal with the threat environment that DoD is facing today.”

Greenwalt and others say the implementation of the Clinger-Cohen Act has led checklists for capital planning, for oversight and for a host of other management processes.

And it’s those checklists, or at least that checklist mentality, that gave the 809 Panel the motive for the recommendation.

Elliott Branch, the deputy assistant secretary for acquisition and procurement in the Office of the Secretary of the Navy for Research, Development and Acquisition, said the authors of Clinger-Cohen did not necessarily focus on DoD, and other similar agencies like NASA and the Energy Department, to implement the law because they had more mature processes to manage complex IT projects.

“The question in the Navy and other services and departments that have fairly robust requirements, resources and acquisition system, is what is the role of the CIO?” Branch said at the Jan. 15 roll out of the final set of recommendations. “That role, in my observation at least in DoD, has been driven by personality as much as anything. It vacillates from trying to get control of the requirements, resources and acquisition process, which is a losing battle because it’s got its own statutory authority, and being a setter of standards, which is a job probably better done by the private sector, who for the most part are highly technical. Essentially, consistent with some of our other recommendations to eliminate paper that do not add value, you take the pieces of Clinger-Cohen that a decision-maker needs to have to make a good decision about an acquisition strategy and fold them into a program plan and get rid of the rest.”

Dave Wennergren, a former DoD deputy CIO and deputy chief management officer, said the checklists tend to force CIOs to worry more about compliance than business needs.

But at the same time, Wennergren, now a managing director with Deloitte Consulting, said the Clinger-Cohen Act and its implementation never stopped him in either his deputy CIO or deputy CMO role from meeting the military’s mission.

“You can drive decisions despite all the statutes. Statues do nothing to stop you from doing the job,” he said. “The issue becomes people too often fall back on the processes and the acquisitions we know. What the power of the 809 panel was, it got  us to think about better ways to do business and drive IT acquisitions that reflect the best and brightest approaches.”

OMB recognized that the capital planning process is broken. Over the last two years, the administration has been moving agencies toward Technology Business Management standards through the Circular A-11 guidance.

OMB said the goal is for TBM to move the planning process from a static effort to a value-added dynamic one that cuts across the entire agency.

The administration also included TBM as part of the President’s Management Agenda cross-agency priority goals. In December, OMB reported mixed results with TBM goals including completing the cost pool implementation report focused on authoritative data needed for the TBM cost pool layer, but also falling behind on developing governmentwide standards.

A more tailored IT management approach needed

Dan Chenok, the executive director for the IBM Center for the Business of Government and former OMB executive, said there is widespread recognition that the implementation of the law has caused acquisitions to slow down.

“I think an approach that would work would be to do a work break down structure of those processes and a simplification exercise to see what you need to do that will lead to improvements in the time it takes to acquire emerging technologies without sacrificing oversight and management,” he said. “A more tailored response to this legitimate problem, which the panel articulated in the report, is to empower the CIO to work within a modernized statutory structure.”

Chenok added the most successful private sector, and for that matter public sector, CIOs drive technology in support of architecture, modernization and mission support as part of an integrated management team.

“The CIO is the IT maestro leading the orchestra and the sections make the music on their own, but the technology often ties them together,” Chenok said. “The statues left room for OMB to issue policy directives that called for enterprise, collaborative technology governance led by CIOs and involving agency CXO partners. But it would be beneficial to update and tie together all the current legislation and policies into a single comprehensive management framework as a roadmap for IT modernization.”

Chenok’s analysis of the CIO’s role is where the 809 Panel really wants DoD, and for that matter all agencies, to recognize acquisition and the application of technology have changed, and recognize the CIO must be a different type of person with different skills, authorities and respect. Agencies who do that are among the most successful in using technology to drive mission and program success.

“Congress, OMB and the IT community are SO distracted from the underlying plot of the Clinger-Cohen Act — it was NEVER about the technology but rather how you could transform mission and support processes through the thoughtful application of technology,” Brubaker said. “Agencies were to demonstrate how they were thoughtfully applying technology by presenting clear and compelling business cases for investing in technology then holding themselves accountable for producing measurable improvements in mission and operational performance. Sadly, OMB, GSA, agencies and CIOs just couldn’t resist the temptation to over-prescribe compliance and pushing tasks that over-focused on technology and infrastructure which completely missed the point.”

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